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Cuba General License 4 - Authorizing Transactions for Third-Country Diplomatic and Consular Missions in Cuba (July 23, 2026)

Date issued: Jul. 23 2026

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OFFICE OF FOREIGN ASSETS CONTROL

Executive Order 14404 of May 1, 2026

Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy

GENERAL LICENSE NO. 4

Authorizing Transactions for Third-Country Diplomatic and Consular Missions in Cuba

(a) Except as provided in paragraph (c) of this general license, all transactions involving persons blocked pursuant to Executive Order (E.O.) 14404 that are ordinarily incident and necessary to the conduct of the official business of third-country diplomatic or consular missions located in Cuba are authorized.

(b) Except as provided in paragraph (c) of this general license, all transactions involving persons blocked pursuant to E.O. 14404 that are ordinarily incident and necessary to the processing of funds transfers and maintenance of accounts for the personal expenditures...

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TURBOFAC Commentary (141 words)

Notes:

1) Compare 515.579 of the CACR, which authorizes “Depository institutions, as defined in § 515.333” (i.e. U.S.-regulated entities) to “process funds transfers for the operating expenses or other official business in Cuba of third-country official missions” and “process funds transfers and maintain accounts for the personal expenditures of the employees, grantees, and contractors, or persons who share a common dwelling as a family member of such employees, grantees, and contractors, of third-country official missions…” There is substantial overlap between this GL and 515.579, but it was likely issued because 515.579 only applies to U.S. financial institutions, such that the secondary sanctions safe harbor at Cuba General License 1 would not apply to otherwise sanctionable transactions of third-country financial institutions for their diplomatic missions (because such transactions are not “authorized or exempt under the...